I don't think so. Expert Dog is an "essential SA" in most carrier games. Giving it up to get access to Expert ASW is a "trade". Expert ASW is relatively rare on big carriers, but giving up Expert Dog is a risky depending on what the opponent brings for aircraft.
I wish to have no connection with any ship that does not sail fast; for I intend to go in harm's way. - Captain John Paul Jones
Just Glorious has Expert ASW. And when you’re looking at 1939, 1940 games, the UK fighters are already hamstrung with needing to rely on Sea Hurricane with maybe some land-based defense.
You also have a lot of cases where you don’t want Flag. All told, it’s an exciting opportunity to choose two different suites of SAs for an essential carrier.
I like Flag 2 + Expert ASW + Expert Torps. Arguably worth 1-2 points more than the existing Ark Royal card (I think only +1, simply due to Flag 2, but precedent could lead to +2).
For the sake of argument, paying +1 or +2 for this is OK if your really want the ASW and/or the Flag. Otherwise, the original is attractive for a slightly lower cost and EDF.
I wish to have no connection with any ship that does not sail fast; for I intend to go in harm's way. - Captain John Paul Jones